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United States Government Accountability Office:
GAO:
Report to Congressional Committees:
March 2012:
Nursing Homes:
CMS Needs Milestones and Timelines to Ensure Goals for the Five-Star
Quality Rating System Are Met:
GAO-12-390:
GAO Highlights:
Highlights of GAO-12-390, a report to congressional committees.
Why GAO Did This Study:
In 2008, in an effort to provide helpful information to consumers and
improve provider quality, the Centers for Medicare & Medicaid Services
(CMS) developed and implemented the Five-Star Quality Rating System
(Five-Star System). The Five-Star System assigns each nursing home an
overall rating and three component ratings—-health inspections,
staffing, and quality measures—-based on the extent to which the
nursing home meets CMS’s quality standards and other measures. The
rating scale ranges from one to five stars, with more stars indicating
higher quality.
The Patient Protection and Affordable Care Act directed GAO to review
CMS’s Five-Star System. This report examines (1) how CMS developed and
implemented the Five-Star System and what key methodological decisions
were made during development, (2) the circumstances under which CMS
considers modifying the Five-Star System, and (3) the extent to which
CMS has established plans to help ensure it achieves its goals for the
Five-Star System. To conduct this work, GAO reviewed CMS documents,
interviewed CMS officials and others, and assessed whether CMS uses
certain strategic planning practices.
What GAO Found:
CMS developed and implemented the Five-Star System largely during an
8-month period in 2008 with input from long-term care stakeholders,
CMS’s Five-Star System contractor, and members of a technical expert
panel—-a panel composed of nine individuals that CMS identified as
experts in long-term care research. CMS made numerous methodological
decisions during the development of the Five-Star System, including
three key methodological decisions. GAO defines key methodological
decisions as those that at least six technical expert panel members-—
of the nine that GAO contacted—recalled as eliciting the most intense
review and discussion during the development of the Five-Star System.
One key methodological decision was how to combine the component
ratings to create an overall rating. The other two key methodological
decisions pertained to how to create ratings that account for
variation in the type of care provided across nursing homes.
CMS generally considers modifying the Five-Star System in response to
(1) methodological issues raised by stakeholders, (2) its routine
monitoring of the system, and (3) the availability of new data
sources. CMS officials explained that when a methodological issue is
raised by long-term care stakeholders, they review the Five-Star
System to determine whether modifications should be made. Officials
said that each issue raised does not always result in modifications to
the Five-Star System, although some minor modifications have been
made. CMS also considers making modifications to the Five-Star System
based on its periodic analyses of trends of the system; however, to
date, no modifications have been made based on these analyses. Lastly,
CMS is currently determining how to modify the staffing and quality
measure ratings of the Five-Star System based on newly available data.
CMS has several planned efforts intended to improve the Five-Star
System, including evaluating the usability of the system, adding
nursing home capability information, revising the staffing component,
and developing additional quality measures. However, CMS lacks GAO-
identified leading strategic planning practices—-the use of milestones
and timelines to guide and gauge progress toward achieving desired
results and the alignment of activities, resources, and goals-—that
could help the agency to more efficiently and effectively accomplish
its planned efforts intended to improve the Five-Star System. While
CMS officials have given us broad estimates for when they anticipate
some of these efforts to be implemented, CMS does not have milestones
and timelines associated with implementing the efforts, which could
help ensure that appropriate progress is made towards implementation.
In addition, CMS has not established, through planning documents, how
its planned efforts to improve the Five-Star System will help CMS
achieve the goals of the system—-to inform consumers and improve
provider quality. As a result, CMS may not be identifying and
prioritizing its intended improvements in a manner that best ensures
that the goals are being achieved.
What GAO Recommends:
GAO recommends that the Administrator of CMS use strategic planning to
establish how its planned efforts will help meet the goals of the Five-
Star System, and develop milestones and timelines for each of its
planned efforts. CMS agreed with these recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-12-390]. For more
information, contact Linda Kohn at (202) 512-7114 or kohnl@gao.gov.
[End of section]
Contents:
Letter:
Background:
CMS Used Input from External Entities on the Development and
Implementation of the Five-Star System, Which Included Three Key
Methodological Decisions:
CMS Typically Considers Modifying the Five-Star System in Response to
Stakeholders, after Routine Monitoring, and When New Data Sources
Become Available:
Although CMS Intends to Make Improvements, the Agency Has Not Ensured
That Its Efforts Will Help Achieve the Goals of the Five-Star System:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Methodology for Identifying Key Methodological Decisions
Made during Five-Star Quality Rating System Development:
Appendix II: Overview of CMS's Five-Star Quality Rating System
Methodology:
Appendix III: Comments from the Department of Health and Human
Services:
Appendix IV: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Key Methodological Decisions Made during the Development of
the Five-Star System, as Identified by CMS's Technical Expert Panel:
Table 2: Health Inspection Score: Weights for Different Types of
Deficiencies Identified in Nursing Homes:
Table 3: Points Added to Health Inspection Score When Repeat Revisits
Are Needed after a Health Inspection Survey Finds Deficiencies:
Table 4: Scoring Method and Thresholds for Assigning Staffing Ratings
in the Five-Star System:
Figures:
Figure 1: Calculating the Overall Rating for the Five-Star System:
Figure 2: Timeline of Development and Implementation of the Five-Star
System, April to December 2008:
Abbreviations:
AHRQ: Agency for Healthcare Research and Quality:
CMS: Centers for Medicare & Medicaid Services:
GPRA: Government Performance and Results Act:
HHS: Department of Health and Human Services:
MDS: Minimum Data Set:
RN: registered nurse:
RUG: Resource Utilization Group:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
March 23, 2012:
The Honorable Max Baucus:
Chairman:
The Honorable Orin Hatch:
Ranking Member:
Committee on Finance:
United States Senate:
The Honorable Fred Upton:
Chairman:
The Honorable Henry Waxman:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Dave Camp:
Chairman:
The Honorable Sander Levin:
Ranking Member:
Committee on Ways and Means:
House of Representatives:
The nation’s almost 3.3 million nursing home residents are a
vulnerable population of elderly and disabled individuals who rely on
nursing homes to provide high-quality care. In 2009, these nursing
home consumers and their families had about 15,900 nursing homes
participating in the Medicare and Medicaid programs from which to
choose for their care needs.[Footnote 1] When deciding on a nursing
home, consumers and their families can make choices based on such
factors as location, fees, specialties, services and activities for
residents, and what they know about the quality of care provided in a
facility. The Centers for Medicare & Medicaid Services (CMS), an
agency within the Department of Health and Human Services (HHS), is
responsible for establishing quality standards that nursing homes must
meet in the delivery of care to their residents and for overseeing
nursing homes’ compliance with those standards. In our prior work, we
have shown that the quality of care provided in nursing homes can
vary, often significantly, and have raised concerns about the quality
of care in some nursing homes. For example, our prior reports have
found that some nursing homes have been cited repeatedly for serious
deficiencies, such as residents having preventable pressure ulcers
that harmed them or put them at risk of death or serious injury.
[Footnote 2]
Given the various factors nursing home consumers may consider when
choosing a facility, including quality of care, the variability in the
quality of care provided across nursing homes, and concerns over
quality of care problems in some nursing homes, CMS has taken steps to
provide assistance to individuals and their families in choosing a
nursing home. Specifically, in 1998 CMS began publicly reporting
information related to the quality of nursing homes on its Nursing
Home Compare website.[Footnote 3] However, in 2007, some members of
Congress raised concerns that this information was not helpful to
consumers because it was difficult to understand.
To address these concerns, in 2008 CMS developed and implemented the
Nursing Home Five-Star Quality Rating System (Five-Star System), which
is posted on the Nursing Home Compare website. The primary goal of the
Five-Star System is to help consumers make informed decisions about
their care by providing understandable and useful information on
nursing home quality. The secondary goal of the Five-Star System is to
help improve nursing home quality by publicly reporting quality of
care information, as some research has suggested that publishing such
information can create an incentive for providers to improve their
quality of care. The Five-Star System assigns each nursing home an
overall rating and three component ratings based on the extent to
which the nursing home meets CMS’s quality standards and other
measures. The rating scale ranges from one to five stars, with more
stars indicating higher quality.
Some long-term care stakeholders have voiced support for the Five-Star
System, stating that it helps consumers choose a nursing home for
themselves or a family member.[Footnote 4] However, other long-term
care stakeholders and some members of Congress have raised questions
about the Five-Star System, such as how the system was developed and
implemented and whether CMS is taking steps to make the system more
useful to consumers. For example, provider advocacy groups have raised
questions about the methodology used to develop the ratings and
consumer advocacy groups have made suggestions on the substance and
presentation of the Five-Star System in an effort to improve the
information provided to consumers.
The Patient Protection and Affordable Care Act directed us to review
CMS’s Five-Star System.[Footnote 5] This report examines (1) how CMS
developed and implemented the Five-Star System and what key
methodological decisions were made during development, (2) the
circumstances under which CMS considers modifying the Five-Star
System, and (3) the extent to which CMS has established plans to help
ensure it achieves its goals for the Five-Star System.
To describe how CMS developed and implemented the Five-Star System,
including the key methodological decisions that CMS made during
development, we interviewed senior CMS officials responsible for the
system about the development and implementation of the system. We
reviewed documents from CMS and its Five-Star System contractor—the
contractor to which CMS awarded a contract to assist with development
and implementation of the system.[Footnote 6] These documents include
those describing how CMS communicated information about the Five-Star
System to individuals and entities outside of CMS, meetings CMS’s
contractor convened with a panel of nine individuals that CMS and its
contractor identified as experts in long-term care research—referred
to in this report as the “technical expert panel”—to solicit and
discuss potential approaches to calculate nursing home ratings, and
the methodology used to calculate the ratings, including the reasoning
behind CMS’s final methodological decisions. Finally, we identified
the key methodological decisions—-which we define as the
methodological decisions that at least six of the members of the
technical expert panel recalled as eliciting the most intense
discussion and review during development of the Five-Star System—-
using a series of interviews and questionnaires. We interviewed all
nine technical expert panel members and received responses to our
questionnaire from seven of the nine members. For additional
information on our approach to identify the key methodological
decisions, see appendix I.
To describe the circumstances under which CMS considers modifying the
Five-Star System, we interviewed senior CMS officials about the
factors that prompt CMS to examine potential modifications to the
system. We also reviewed documents describing modifications made to
the Five-Star System since its implementation in December 2008 and the
reasons those modifications were made. In addition, we reviewed
analyses of the Five-Star System’s rating results that CMS’s Five-Star
System contractor has been conducting since the system’s
implementation in December 2008.
To describe the extent to which CMS has established plans to help
ensure it achieves its goals for the Five-Star System, we interviewed
CMS officials, including senior officials responsible for the Five-
Star System, those involved in strategic planning for the agency, and
those involved in displaying health care information for consumers on
CMS’s websites. We identified and reviewed documents related to CMS’s
plans for improving the Five-Star System as well as documents that
relate to the system’s goals—informing consumers and improving
provider quality. We interviewed officials and reviewed documents from
the HHS Agency for Healthcare Research and Quality (AHRQ) regarding
best practices AHRQ has identified for effectively displaying health
care quality information to consumers on websites. Since the mid-
1990s, we have identified a variety of leading practices for effective
strategic planning in accordance with the Government Performance and
Results Act (GPRA).[Footnotes 7,8] We assessed whether CMS’s plans for
improving the Five-Star System and achieving its goals include two GAO-
identified leading practices for successful strategic planning and
management: (1) using intermediate goals and measures to show progress
or contribution to intended results, and (2) aligning activities and
resources to support agency goals.
We conducted this performance audit from June 2011 through March 2012
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Background:
CMS has publicly reported information on nursing home quality on its
Nursing Home Compare website since 1998 and has increased the amount
of information it reports on the website over time.[Footnote 9] On
June 18, 2008, CMS announced its plans to make use of the information
available on the Nursing Home Compare website and begin assigning each
nursing home "star" ratings to help beneficiaries, their families, and
caregivers compare nursing homes more easily. Beginning in December
2008, CMS made the Five-Star System publicly available on its Nursing
Home Compare website. The Five-Star System assigns star ratings for
each nursing home participating in the Medicare and/or Medicaid
programs. These star ratings include a separate rating for each of the
three components--health inspections, staffing, and quality measures--
in addition to an overall rating.[Footnote 10]
* Health inspection rating. CMS contracts with state survey agencies
to conduct unannounced, on-site nursing home health inspections--known
as surveys--to determine whether nursing homes meet federal quality
standards. Every nursing home receiving Medicare or Medicaid payment
must undergo a standard survey not less than once every 15 months, and
the statewide average interval for these surveys must not exceed 12
months.[Footnote 11] State surveyors also conduct complaint
investigations in response to allegations of quality problems. State
surveyors may spend several days in the nursing home to assess whether
the nursing home is in compliance with federal quality standards. If
nursing homes are found to be out of compliance with any requirements,
state surveyors issue deficiency citations that reflect the scope
(number of residents affected) and severity (level of harm to
residents) of the deficiency. The health inspection rating is a result
of nursing home performance on surveys and complaint investigations.
[Footnote 12]
Specifically, this star rating is based on the scope and severity of
deficiencies from the last 3 years of routine surveys and complaint
investigations. To calculate this rating, the most recent survey
findings are weighted more heavily than those from the prior 2 years.
A nursing home's health inspection rating is relative to other nursing
homes' health inspection ratings in their state. This rating is
updated for each nursing home when new survey data become available
for that facility.
* Staffing rating. Nursing homes self-report staffing hours for a 2-
week period at the time of the routine survey. CMS converts the
reported point-in-time staffing hours for nursing staff--registered
nurses, licensed practical nurses, and certified nursing assistants--
into measures that indicate the number of registered nurse and total
nursing hours per resident per day.[Footnote 13]
This star rating is based on the reported registered nurse and total
nursing staffing levels, adjusted for differences in the level of
complexity of nursing services required to care for residents across
nursing homes--referred to as resident acuity. The adjustment for
resident acuity is done using data from a resident assessment tool
called the Minimum Data Set (MDS), which nursing homes complete and
periodically report to CMS. MDS collects information on residents'
health, physical functioning, mental status, and general well-
being.[Footnote 14] Each nursing home's staffing rating is assigned
based on how its total nursing and registered nurse staffing levels
compare to the distribution of staffing levels for freestanding
facilities[Footnote 15] in the nation and staffing level thresholds
identified by CMS.[Footnote 16] In addition, this rating is updated
when new staffing data are collected at the time of the routine
survey, generally every 12 months.
* Quality measure rating. CMS uses data from MDS to calculate various
quality measures for each nursing home. These measures include, for
example, the prevalence of pressure sores and changes in residents'
mobility.[Footnote 17]
This star rating is based on 10 different quality measures. This
rating is typically updated quarterly. Quality measure ratings are
assigned to generally achieve the following distribution: the top 10
percent of nursing homes receive five stars, the bottom 20 percent
receive one star, and the middle 70 percent of nursing homes receive
two, three, or four stars, with equal proportions (23.33 percent) in
each category.[Footnote 18] However, CMS has not updated the quality
measure ratings since January 2011 to allow CMS to collect resident
information from nursing homes using a new version of MDS and refine
and test quality measures using this revised assessment tool.
The overall star rating is calculated using a process that combines
the star ratings from the health inspection, staffing, and quality
measure components. The overall rating is assigned based on the
following steps:
1. Start with the number of stars for the health inspection rating.
2. Add one star if the staffing rating is four or five stars and also
greater than the health inspection rating. Subtract one star if the
staffing rating is one star. The rating cannot go above five stars or
lower than one star.
3. Add one star if the quality measure rating is five stars. Subtract
one star if the quality measure rating is one star. The rating cannot
go above five stars or lower than one star.[Footnote 19]
See figure 1 for an example of how a nursing home's overall rating is
calculated. This rating is updated when any of the three component
ratings change. For example, changes to the quality measure rating
could change a nursing home's overall rating.
Figure 1: Calculating the Overall Rating for the Five-Star System:
[Refer to PDF for image: illustration]
Step 1:
The process to calculate the overall rating begins with the health
inspection rating.
Example of a health inspection rating for Nursing Home X: Nursing Home
X received four stars during its health inspection rating. Therefore,
it gets four stars in its calculation;
Health inspection rating for Nursing Home X: 4 stars.
Step 2:
For the staffing rating one star is added to the overall rating for a
four or five-star staffing rating and one star is subtracted for one-
star. All other staffing ratings do not affect the overall rating.
Example of a staffing rating for Nursing Home X: Nursing Home X's
staffing rating was four stars, so it was able to add a star;
Staffing rating for Nursing Home X: plus 1 star.
Step 3:
For the quality measure rating, one star is added to the overall
rating for a five-star quality measure rating and one star is
subtracted for a one-star quality measure rating. All other quality
measure ratings do not affect the overall rating.
Example of a quality measure rating for Nursing Home X: Nursing Home
X's quality measure rating was three stars, so there was no effect on
the overall rating;
Quality measure rating for Nursing Home X: no stars.
Overall rating calculation: 5 stars.
Source: GAO analysis of CMS information.
[End of figure]
See appendix II for additional information on the methodology for
calculating nursing home ratings under the Five-Star System.
CMS Used Input from External Entities on the Development and
Implementation of the Five-Star System, Which Included Three Key
Methodological Decisions:
CMS developed and implemented the Five-Star System largely during an 8-
month period with input from long-term care stakeholders, its Five-
Star System contractor, and members of a technical expert panel. CMS
made numerous methodological decisions during the development of the
Five-Star System, including three key methodological decisions that
elicited the most discussion during development.
CMS Solicited Input from Long-term Care Stakeholders, a Contractor,
and a Panel of Experts:
CMS largely developed and implemented the Five-Star System during an 8-
month period from April to December 2008, soliciting input from long-
term care stakeholders, the Five-Star System contractor, and members
of a technical expert panel. For example, after the Acting
Administrator of CMS directed CMS officials to develop a rating system
for nursing homes in late April 2008, CMS obtained comments about the
planned rating system from long-term care stakeholders through an Open
Door Forum[Footnote 20] in June 2008. CMS also reviewed and summarized
comments it received via an email account set up specifically for
comments regarding the planned rating system through late July.
[Footnote 21] Concurrently, CMS developed the methodology to calculate
nursing home ratings in collaboration with the Five-Star System
contractor and members of a technical expert panel. CMS's contractor
established this panel, composed of nine members that the contractor
and CMS identified as experts in long-term care and that included
researchers and an industry representative, to help guide the
development and implementation of the Five-Star System.[Footnote 22]
CMS and its contractor convened five meetings with the technical
expert panel between July and December 2008 to review and discuss
analyses conducted by the Five-Star System contractor regarding
various options for calculating the ratings. In November and December
2008, CMS hosted meetings with reporters and other government
entities, including the HHS Administration on Aging, and hosted
another Open Door Forum to discuss the impending implementation of the
Five-Star System with stakeholders. In December 2008, CMS gave nursing
home providers a preview of their ratings and, on December 18, 2008,
CMS made the Five-Star System publicly available on the Nursing Home
Compare website. (See figure 2 for a timeline of CMS's development and
implementation of the Five-Star System.)
Figure 2: Timeline of Development and Implementation of the Five-Star
System, April to December 2008:
[Refer to PDF for image: time line]
Development and implementation steps:
CMS Acting Administrator directed CMS officials to develop a quality
rating system:
Event date range: Late April, 2008.
CMS officials hosted meetings with stakeholders, other government
entities, and reporters;
Event date range: May-June, 2008.
CMS solicited comments about the planned rating system[A];
Event date range: Late June-Mid-July, 2008;
CMS convened meetings with its Five-Star System contractor and
technical expert panel;
Event date range: Mid-July-Mid-December, 2008;
CMS provided nursing homes with a preview of their ratings;
Event date range: Mid-December, 2008;
CMS publicly reports the Five-Star System on the Nursing Home Compare
website;
Event date range: Mid-December, 2008-ongoing.
Source: GAO analysis of CMS information.
[A] CMS continued to receive comments on the Five-Star System via
email after July 2008, though those comments were not included in
CMS's summary of comments on the system.
[End of figure]
Three Key Methodological Decisions Elicited the Most Discussion during
Development:
CMS made numerous methodological decisions during the development of
the Five-Star System, including three key methodological decisions. We
define key methodological decisions as those that at least six members
of CMS's technical expert panel recalled as eliciting the most intense
review and discussion during the development of the Five-Star System.
[Footnote 23] According to the panel experts, one key methodological
decision was how to combine the component ratings to create an overall
rating. The other two key methodological decisions pertain to how to
create ratings that account for variation in the type of care provided
across nursing homes. Specifically, the second key methodological
decision the experts recalled was whether to exclude hospital-based
nursing homes or set up separate ratings for hospital-based and
freestanding nursing homes.[Footnote 24] The third key methodological
decision the experts recalled was whether the staffing rating should
be based on nursing staffing levels that are adjusted to reflect
resident acuity.
* How to combine the component ratings to create an overall rating.
One key methodological decision that CMS made was deciding how to best
combine the health inspection, quality measure, and staffing component
ratings to create an overall rating. Technical expert panel members
told us that they discussed how much weight should be assigned to each
component when combining the component ratings to calculate the
overall rating. One technical expert panel member told us that, in the
end, the members generally agreed to assign more weight to the health
inspection and staffing components and less weight to the quality
measure component, which reflects differences in the perceived
validity and reliability of the data used to calculate these
components. Consistent with the technical expert panel's proposal, CMS
decided to assign overall ratings to each nursing home by starting
with the health inspection rating, then adding or subtracting stars if
the nursing home's staffing or quality measure rating was particularly
high or low, with a minimum and maximum rating of one and five stars,
respectively.[Footnote 25]
* Whether to exclude hospital-based nursing homes or set up separate
ratings for hospital-based and freestanding nursing homes. Another key
methodological decision that CMS made was whether to exclude nursing
homes that are hospital-based from the Five-Star System or to set up
separate ratings for hospital-based and freestanding nursing homes.
CMS's Five-Star System contractor stated that hospital-based
facilities may typically provide a different type of care than
freestanding facilities. That is, hospital-based facilities may
provide care to more acute residents who require more extensive
services than freestanding facilities. However, one senior CMS
official told us that some hospital-based and freestanding facilities
may provide care to similar types of residents. While CMS considered
creating separate ratings for hospital-based and freestanding nursing
homes, CMS ultimately decided not to exclude hospital-based nursing
homes or create a separate rating scale for hospital-based and
freestanding nursing homes.
* Whether staffing ratings should be based on nursing staffing levels
that are adjusted to reflect resident acuity. A third key
methodological decision that CMS made was whether the staffing rating
that nursing homes receive should be based on reported staffing levels
that are adjusted to account for resident acuity. For example, in a
published article, two of the technical expert panel members and
others argued that the appropriate level of nurse staffing may differ
substantially in two nursing homes with identical numbers of staff,
because of the differences in the amount of time needed to care for
residents due to variation in resident acuity.[Footnote 26] However,
panel members told us that they debated whether and the extent to
which nursing staffing levels should be adjusted to reflect resident
acuity due to concerns about the validity of existing adjustment
approaches. Because CMS agreed that nursing home staffing levels
should reflect the care needs of the facility's residents, CMS decided
to adjust staffing levels for differences in the expected amount of
time required to care for residents and worked with the technical
expert panel to select an adjustment method.[Footnote 27]
CMS Typically Considers Modifying the Five-Star System in Response to
Stakeholders, after Routine Monitoring, and When New Data Sources
Become Available:
CMS generally considers modifying the Five-Star System in response to
(1) methodological issues raised by stakeholders, (2) its routine
monitoring of the system, and (3) the availability of new data
sources. CMS officials explained that when a methodological issue is
raised by long-term care stakeholders, they review the Five-Star
System to determine whether modifications should be made.[Footnote 28]
Officials further said that each issue raised does not always result
in modifications to the Five-Star System, although some minor
modifications have been made. For example, in September 2009, in
response to input it received from long-term care stakeholders, CMS
updated the methodology for calculating a nursing home's health
inspection rating. With the methodological change, the health
inspection rating for a nursing home is no longer updated unless new
survey data for that nursing home becomes available. Initially,
because each nursing home's health inspection rating is relative to
the ratings of all nursing homes in the same state, the results of new
surveys and rating changes for some nursing homes could have affected
the ratings for other nursing homes in the state. Stakeholders had
noted to CMS that the rating of an individual nursing home therefore
could be changed even if that nursing home had not had a new survey.
CMS made the methodological change to address this concern, while
noting that this had happened to only a small percentage of nursing
homes.
Some issues raised by stakeholders have not resulted in a modification
of the Five-Star System. For example, one stakeholder raised a concern
that surveys should have fixed thresholds instead of thresholds that
are relative to--or based on--other nursing homes' survey scores in
the same state. CMS reviewed this concern with its Five-Star System
contractor and found that fixed thresholds would likely present
disadvantages to nursing homes because changes in survey policy could
lead to changes in survey scores and result in significant changes for
nursing homes' health inspection ratings.[Footnote 29] CMS officials
stated that using a relative distribution allows nursing homes'
ratings to remain more stable and, additionally, allows consumers to
compare nursing homes within a state.
CMS also considers making modifications to the Five-Star System based
on its periodic analysis of the system's rating trends; however, to
date, no modifications have been made based on these analyses. CMS's
Five-Star System contractor conducts this analysis and provides
monthly reports to CMS as well as an annual report that describes
changes over time in nursing homes' ratings and trend information on
the individual components of the system.[Footnote 30] These routine
monitoring reports are intended to help CMS evaluate the Five-Star
System and determine if modifications are needed. For example, CMS
examined whether it should modify the health inspection component
because some state survey agencies have begun using the Quality
Indicator Survey to collect survey information.[Footnote 31] In 2010,
as part of its analysis for one of its monthly reports, CMS examined
whether the health inspection rating of facilities that were inspected
using the Quality Indicator Survey differed from those that were
inspected with the traditional, paper-based survey. No significant
difference was found between the two approaches to conducting the
survey and, as a result, CMS did not modify the Five-Star System.
Lastly, CMS is currently considering how to modify the Five-Star
System because new data sources have become available. Specifically,
CMS is determining, with input from its Five-Star System contractor
and the technical expert panel, how to modify the staffing and quality
measure ratings of the Five-Star System based on new data available
from MDS 3.0, an updated version of the resident assessment tool. CMS
is examining how using data from MDS 3.0 to adjust staffing data to
account for resident acuity will affect the staffing ratings of
nursing homes. In addition, CMS is considering whether the
availability of these new data should result in a modification to the
manner in which the thresholds for the staffing component ratings are
determined. CMS intends to complete any modifications to the staffing
component rating based on the new data by April 2012. CMS is also
currently refining and testing the nursing home quality measures using
MDS 3.0 data and is considering options for modifying how the quality
measure component rating for the Five-Star System will be calculated
using these new data. CMS anticipates that the quality measure
component of the Five-Star System will be modified at the end of
calendar year 2012. Because of these changes, CMS has not updated the
Five-Star System quality measure ratings for individual nursing homes
since January 2011--the last time period for which data using the
previous assessment tool were available.
Similarly, CMS is considering modifying the data it uses to calculate
the nursing home staffing rating based on another new data source--
electronic payroll data. Although CMS currently calculates this rating
based on staffing data from a 2-week period of time, CMS plans to use
payroll records of nursing homes to collect staffing data from nursing
homes, once these data are available in the next 3 to 5 years. A CMS
official told us that the agency has determined what type of data it
wants to collect through nursing home payroll systems, such as data
that will allow the calculation of nursing staff turnover in a nursing
home, and is working with a private firm to develop the system to
collect this information. Electronic payroll data have several
strengths, including that they will allow CMS to collect data on
several aspects of staffing that are not currently available,
including the percentage of staff that are full time and the number of
staff that provide direct patient care. In addition, because payroll
data originate from employees and are used to pay their salaries, CMS
officials stated that they have greater confidence in the accuracy of
the data. According to one senior official, CMS does not expect to
determine potential modifications to the nursing home staffing rating
of the Five-Star System until it has experience collecting payroll
data.
Although CMS Intends to Make Improvements, the Agency Has Not Ensured
That Its Efforts Will Help Achieve the Goals of the Five-Star System:
CMS has several planned efforts intended to improve the Five-Star
System. However, CMS has not taken steps to ensure that these efforts
will help CMS achieve its goals for the Five-Star System--to inform
consumers and improve provider quality. Specifically, CMS has not
established intermediate goals and measures--such as interim
milestones and related timelines--to guide the implementation of these
efforts. In addition, CMS has not established how any changes
resulting from these efforts, if implemented, will support the goals
of the Five-Star System.
CMS Has Identified Efforts Intended to Improve the Five-Star System,
but Lacks Milestones and Timelines to Guide Implementation:
CMS has awarded contracts for or begun discussions about several
planned efforts it has identified to improve the Five-Star System.
These plans include evaluating its usability, adding information on
nursing home capability, revising the staffing component, and
developing additional quality measures. Specifically, CMS's planned
efforts are:
* To evaluate the usability of the Nursing Home Compare website, which
includes the Five-Star System. CMS plans to conduct a multiphase
evaluation of the usability of the Nursing Home Compare website, which
includes the Five-Star System, including testing the website with
consumers and surveying stakeholders. In an effort to integrate the
website with CMS's other "compare" websites, such as Hospital Compare
and Home Health Compare, CMS is currently redesigning the website. As
part of this redesign, CMS is changing the appearance of Nursing Home
Compare to be similar to that of other compare websites.[Footnote 32]
To inform this redesign, in December 2011, CMS tested proposed web
page layouts for the revised website with a group of nine
participants.[Footnote 33] However, according to a senior CMS
official, this testing and evaluation have been limited in scope and
depth due to time constraints[Footnote 34] and are only the first step
toward gathering information on the usability of the Nursing Home
Compare website and Five-Star System. The official stated that CMS
plans to conduct a more in-depth evaluation of the Nursing Home
Compare website and the Five-Star System than any done to date--one
that includes more detailed consumer testing, a survey of long-term
care stakeholders, and a web-based pop-up survey. CMS's Five-Star
System contractor will assist with the more in-depth evaluation of the
usability of the Nursing Home Compare website and the Five-Star System
in fiscal year 2012.
* To evaluate options to better distinguish among nursing homes'
various care capabilities. A senior CMS official stated that CMS is
evaluating options for refining the Nursing Home Compare website and
the Five-Star System to incorporate additional information about
particular nursing home capabilities, such as whether a nursing home
specializes in rehabilitative short-stay versus long-stay care.
[Footnote 35] One option is to post information on particular
capabilities, such as whether a nursing home has a rehabilitation or
dementia support unit. Another option under review is the creation of
a rating system that assigns ratings separately for nursing homes that
primarily provide short-stay care and for those that primarily provide
long-stay care. In fiscal year 2012, CMS's Five-Star System contractor
will develop options for additional information that might be
collected regarding specific capabilities of nursing homes that would
be useful to CMS or Nursing Home Compare and Five-Star System users.
* To evaluate options to include other types of nursing home staff in
the staffing component rating. A senior CMS official stated that CMS
would like to include some non-nurse staff, such as therapy staff, in
the staffing component of the Five-Star System.[Footnote 36] However,
CMS must first evaluate the feasibility and options for including
additional staff. Subject to this evaluation, CMS officials said they
would like to include some non-nursing staff in the staffing component
by January 2013. CMS already collects data from nursing homes on some
non-nursing staff levels, including therapy staff, but does not
currently use this information to calculate the staffing rating.
* To develop more quality measures for the quality measure component
rating. CMS is in the initial stages of identifying additional nursing
home quality measures for use in the Five-Star System. CMS's Five-Star
System contractor has been tasked with identifying potential measures
for use in the Five-Star System in fiscal years 2011 and
2012.[Footnote 37] A senior CMS official stated that identifying
quality measures for the Five-Star System is an ongoing task under the
contract and includes working with experts in the field of nursing
home quality measure development, reviewing literature, and analyzing
the results of potential quality measure data, such as data generated
from MDS 3.0. In meetings with the technical expert panel, CMS and its
contractor have solicited feedback from panel members on quality
measures that would improve the Five-Star System.
Although CMS has several planned efforts intended to improve the Five-
Star System, the agency has not established intermediate goals and
measures--such as interim milestones and related timelines--that could
be used to show progress or contribution towards implementing these
efforts. Specifically, while CMS officials have given us broad
estimates for when they anticipate some of these efforts to be
undertaken, CMS does not have planning documents or strategies that
outline specific milestones and timelines associated with implementing
the agency's planned efforts to improve the Five-Star System. We have
found, in our prior work, that developing and using specific
milestones and timelines to guide and gauge progress toward achieving
an agency's desired results is a leading practice for effective
strategic planning and management.[Footnote 38] Particularly because
much of the implementation is to be conducted by the Five-Star System
contractor, the use of milestones and timelines to guide and gauge
implementation is especially useful for helping to ensure that CMS has
clear expectations for its contractor and a means for determining
whether appropriate progress has been made in implementing these
efforts.
CMS Has Not Established How Its Planned Efforts Will Help Achieve
Goals:
CMS has not established, through planning activities or resulting
planning documents, how its planned efforts to improve the Five-Star
System will help CMS achieve the goals of the system--to inform
consumers and improve provider quality. As a result, CMS may not be
identifying and prioritizing its efforts in a manner that best ensures
that the goals are being achieved. We have found, in our prior work,
that aligning activities, resources, and goals is a leading strategic
planning practice that can help agencies to more efficiently and
effectively achieve their goals.[Footnote 39]
CMS officials stated that the agency has no planning activities or
resulting planning documents that link the Five-Star System's goals
with CMS's efforts to improve the system and that establish priorities
among the efforts, based on these goals. This lack of planning and
priority setting may explain why CMS has taken limited steps to
determine whether or to what extent the Five-Star System is achieving
the primary goal of providing consumers with understandable and useful
information on nursing home care. For example, consumer testing of the
Five-Star System could provide information on the extent to which this
goal is being achieved. According to AHRQ, consumer testing is a key
practice for ensuring that health care quality information is publicly
reported in a manner that is useful and understandable to
consumers.[Footnote 40] However, CMS has gathered very limited
information from consumers regarding the usefulness of the Five-Star
System[Footnote 41] and it appears that CMS has not prioritized its
efforts based on the goal of informing consumers.
In addition, CMS has not set specific priorities among its planned
efforts based on how to best achieve the secondary goal of the Five-
Star System--to improve provider quality. For example, while public
reporting itself can be an incentive for providers to improve quality,
there may be other efforts that could help CMS to further accomplish
this goal. Nursing home quality measures serve a number of purposes,
including providing data to nursing homes to help with their own
quality improvement efforts. In addition, making quality measure
information available to consumers allows them to distinguish among
nursing homes' quality and provides an incentive for providers to
improve their quality. Therefore, adding more individual quality
measures to that rating component in the Five-Star System could
potentially create even greater incentives as well as provide nursing
homes with more data on how to improve the quality of their care.
However, CMS has not explicitly prioritized this planned effort or
others based on achievement of this secondary goal. This planning and
prioritization is especially important for quality measures because
quality measures can be costly and time intensive to develop,
especially if new data need to be collected in order to create the
measures.
CMS officials said that the agency has no planning activities or
resulting planning documents related to the Five-Star System because
there are too many intervening circumstances that make planning
difficult. These include uncertainty about resources available for the
Five-Star System due to competing resource needs within the agency,
mandatory activities required by the Patient Protection and Affordable
Care Act that take up staff time and effort, and other agency
initiatives. However, CMS officials acknowledged that, as CMS's budget
is more constrained, the development of planning documents that
prioritize its efforts intended to improve the Five-Star System will
become increasingly important.
Conclusions:
In an attempt to make information on nursing home quality easier for
consumers to understand and use, and to help improve provider quality,
CMS developed and implemented the Five-Star System in 8 months using
information that was readily available. This was a significant step
toward increasing the transparency of information important to
consumers, but for CMS to sustain the Five-Star System over time, the
agency will need to continue making a concerted effort. CMS has made
some efforts to update the Five-Star System as it reviews the system's
underlying components to identify potential ways to improve the system
over time. However, there can be significant challenges to ensuring
that the Five-Star System remains useful and valid over time,
especially when the components of that system continue to evolve.
While CMS has identified efforts it intends to make to improve the
Five-Star System, the agency has not strategically planned how to
carry out these efforts, such as outlining the milestones and
timelines that will help ensure that progress is being made. In
addition, CMS has not clearly identified how each of its planned
efforts will help achieve the goals of the Five-Star System. As a
result, CMS may not know how it will prioritize and best leverage its
available resources to implement these efforts and achieve the goals
of the Five-Star System. Additionally, during this period of fiscal
constraint, these strategic planning practices can help CMS to better
anticipate and make resource allocation decisions that minimize the
effect of funding constraints on accomplishing the goals of the Five-
Star System.
Recommendations for Executive Action:
In order to strengthen CMS's efforts to improve the Five-Star System,
we recommend that the Administrator of CMS use strategic planning
practices to:
* establish--through planning documents--how its planned efforts will
help CMS achieve the goals of the Five-Star System, and:
* develop milestones and timelines for each of its planned efforts.
Agency Comments:
We received written comments on a draft of this report from HHS on
behalf of CMS, which are reprinted in appendix III. CMS agreed with
our recommendations and submitted general comments on the draft.
Specifically, CMS agreed with our recommendation to establish--through
planning documents--how its planned efforts will help CMS achieve the
goals of the Five-Star System. CMS stated that it will work to develop
a strategic plan for the Five-Star System that will address the short-
and long-term goals for the system and the manner in which those goals
will be achieved. CMS said that it would include a mechanism for
receiving regular input from consumers and other stakeholders as part
of a strategic plan. CMS also agreed with our recommendation to
develop milestones and timelines for each of its planned efforts. CMS
acknowledged the importance of both a strategic plan and the use of
specific timelines and milestones for measuring progress toward
meeting the goals of the Five-Star System and budgeting for the
resources needed to meet those goals.
We are sending copies of this report to the Secretary of HHS and the
Administrator of CMS and other interested parties. In addition, the
report also will be available at no charge on GAO's website at
[hyperlink, http://www.gao.gov].
If you or your staff members have any questions about this report,
please contact me at (202) 512-7114 or kohnl@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this report. Key contributors to this report
are listed in appendix IV.
Signed by:
Linda T. Kohn:
Director, Health Care:
[End of section]
Appendix I: Methodology for Identifying Key Methodological Decisions
Made during Five-Star Quality Rating System Development:
To identify the key methodological decisions made during the
development of the Five-Star Quality Rating System (Five-Star System),
defined as those that caused the most intense discussion and review
according to at least six members of the Centers for Medicare &
Medicaid Services' (CMS) technical expert panel, we solicited the
views of panel members through a series of interviews and
questionnaires.[Footnote 42]
Specifically, we completed the following steps:
1. We interviewed each member of the technical expert panel using a
structured interview set containing open-ended questions. During these
interviews, we asked each member to provide their views on the top
three methodological decisions that caused the most discussion and
review during the development of the Five-Star System and to describe
the differing views expressed by members of the panel on the
methodological approach that CMS was considering.
2. We summarized the open-ended interview responses related to the
views on the methodological decisions that caused the most discussion
and review during the development of the Five-Star System.
3. We distributed a questionnaire to the members of the technical
expert panel that outlined the methodological decisions identified
during our interviews and asked each member to identify the six
methodological decisions they recalled as eliciting the most intense
review and discussion during the development of the Five-Star System.
4. We analyzed the responses to our questionnaire to identify the key
methodological decisions--those that at least six members of CMS's
technical expert panel recalled as eliciting the most intense review
and discussion during the development of the Five-Star System. Seven
of nine technical expert panel members responded to our questionnaire.
We made multiple unsuccessful attempts to obtain completed
questionnaires from the remaining two members over a 4 week period.
(See table 1.)
Table 1: Key Methodological Decisions Made during the Development of
the Five-Star System, as Identified by CMS's Technical Expert Panel:
Methodological decisions: Which information from surveys to use to
calculate the ratings;
Key methodological decision[A]: [Empty].
Methodological decisions: Which thresholds to use for assigning health
inspection ratings[B];
Key methodological decision[A]: [Empty].
Methodological decisions: What staffing information, if any, to
include in the rating system;
Key methodological decision[A]: [Empty].
Methodological decisions: Whether and how to adjust staffing levels to
reflect resident acuity[C];
Key methodological decision[A]: [Check].
Methodological decisions: How to combine the staffing measures to
calculate the staffing ratings;
Key methodological decision[A]: [Empty].
Methodological decisions: Which thresholds to use for assigning
staffing ratings[B];
Key methodological decision[A]: [Empty].
Methodological decisions: Whether to exclude hospital-based facilities
or set up separate staffing ratings for hospital-based and
freestanding nursing homes[D];
Key methodological decision[A]: [Empty].
Methodological decisions: Which quality measures to include in the
quality measure rating;
Key methodological decision[A]: [Empty].
Methodological decisions: Whether and how to risk adjust the quality
measures;
Key methodological decision[A]: [Empty].
Methodological decisions: How to combine the individual measures to
calculate the quality measure rating;
Key methodological decision[A]: [Empty].
Methodological decisions: Which thresholds to use to assign quality
measure ratings[B];
Key methodological decision[A]: [Empty].
Methodological decisions: Whether to create an overall rating;
Key methodological decision[A]: [Empty].
Methodological decisions: How to combine the component ratings to
create an overall rating;
Key methodological decision[A]: [Check].
Methodological decisions: Which thresholds to use to assign an overall
rating[B];
Key methodological decision[A]: [Empty].
Methodological decisions: Whether to exclude or set up separate
overall ratings for hospital-based and freestanding nursing homes[D];
Key methodological decision[A]: [Check].
Source: GAO analysis of interviews with members of the technical
expert panel that CMS convened to assist with the development of the
Five-Star System.
[A] We defined key methodological decisions as those identified by six
or more of the members of CMS's technical expert panel as eliciting
the most intense review and discussion during the development of the
Five-Star System.
[B] Thresholds refer to cut points above or below which nursing homes
would be awarded a specific number of stars or points to be used to
calculate star ratings.
[C] Resident acuity refers to the differences in the level of
complexity of nursing services required to care for residents across
nursing homes.
[D] Hospital-based nursing homes are under administrative control of a
hospital. In contrast, freestanding nursing homes are those that are
not under administrative control of a hospital.
[End of table]
[End of section]
Appendix II: Overview of CMS's Five-Star Quality Rating System
Methodology:
In the Five-Star System, nursing homes are assigned ratings for three
components--health inspections, staffing, and quality measures--and an
overall rating. These ratings range from one star to five stars, with
more stars indicating higher quality.
Health Inspection Rating:
Each nursing home is assigned a health inspection rating in comparison
to other nursing homes in its state using a point system. These points
are assigned based on the nursing home's three most recent health
inspections--known as a survey--results, including survey revisits and
complaint surveys, over the past 3 years.[Footnote 43] Points are
assigned based on the number, scope, and severity of a nursing home's
health deficiencies found during surveys, with deficiencies with
greater scope and severity equating to more points. Therefore, a lower
survey point total results in a better rating (see table 2). If
multiple revisits are required to ensure that major deficiencies are
corrected, additional points are added to the health inspection score
(see table 3). Based on the totals received, the top 10 percent of
nursing homes in a given state receive five stars, the bottom 20
percent receive one star, and the middle 70 percent of nursing homes
receive two, three or four stars, with equal proportions (23.33
percent) in each category.
Table 2: Health Inspection Score: Weights for Different Types of
Deficiencies Identified in Nursing Homes:
Severity: Immediate jeopardy[A];
Scope: Isolated: J; 50 points[B] (75 points);
Scope: Pattern: K; 100 points[B](125 points);
Scope: Widespread: L; 150 points[B](175 points)).
Severity: Actual harm;
Scope: Isolated: G; 20 points;
Scope: Pattern: H; 35 points (45 points);
Scope: Widespread: I; 45 points (50 points).
Severity: Potential for more than minimal harm;
Scope: Isolated: D; 4 points;
Scope: Pattern: E; 8 points;
Scope: Widespread: F; 16 points (20 points).
Severity: Potential for minimal harm[C];
Scope: Isolated: A; 0 points;
Scope: Pattern: B; 0 points;
Scope: Widespread: C; 0 points.
Source: CMS.
Note: Points are assigned to deficiencies based on the scope and
severity of the deficiency and whether the deficiency constitutes
substandard quality of care. Figures in parentheses indicate points
for deficiencies that are for substandard quality of care.
Deficiencies constitute substandard quality of care if they are cited
at the scope/severity levels F or H through L because the nursing home
did not meet a quality of care standard under the following federal
regulations: 42 C.F.R § 483.13 (resident behavior and nursing home
practices); 42 C.F.R § 483.15 (quality of life); 42 C.F.R § 483.25
(quality of care).
[A] Actual or potential for death/serious injury.
[B] If the status of the deficiency is identified as "past non-
compliance" and the severity is Immediate Jeopardy, then points
associated with a "G level" deficiency (i.e., 20 points) are assigned.
[C] Nursing home is considered to be in substantial compliance.
[End of table]
Table 3: Points Added to Health Inspection Score When Repeat Revisits
Are Needed after a Health Inspection Survey Finds Deficiencies:
Number of revisit surveys: First;
Points: 0.
Number of revisit surveys: Second;
Points: 50 percent of health inspection score.
Number of revisit surveys: Third;
Points: 70 percent of health inspection score.
Number of revisit surveys: Fourth;
Points: 85 percent of health inspection score.
Source: CMS.
[End of table]
Staffing Rating:
Each nursing home's staffing rating is calculated based on the
facility's self-reported registered nurse (RN) and total nursing (sum
of RN, licensed practical nurse, and certified nursing assistant)
staffing levels for a 2-week period around the time a routine survey
is conducted. Staffing levels are converted to hours per resident day
and are adjusted to reflect varying levels of resident
acuity.[Footnote 44] Each nursing home's staffing rating is assigned
based on how its total nursing and RN staffing levels compare to the
distribution of staffing levels for freestanding facilities[Footnote
45] in the nation and staffing level thresholds identified by
CMS.[Footnote 46] (See table 4.)
Table 4: Scoring Method and Thresholds for Assigning Staffing Ratings
in the Five-Star System:
Star rating[A]: 1;
Definition: Less than 25th percentile[C];
Range (adjusted hours per resident day): less than 0.221;
Registered nurses Total nursing[B]: less than 2.998.
Star rating[A]: 2;
Definition: At least 25th percentile but less than median[C];
Range (adjusted hours per resident day): greater than or equal to
0.221 - less than 0.298;
Registered nurses Total nursing[B]: greater than or equal to 2.998 -
less than 3.376.
Star rating[A]: 3;
Definition: Greater than or equal to the median but less the 75th
percentile[C];
Range (adjusted hours per resident day): greater than or equal to
0.298 - less than 0.402;
Registered nurses Total nursing[B]: greater than or equal to 3.376 -
less than 3.842.
Star rating[A]: 4;
Definition: Greater than or equal to the 75th percentile[C];
Range (adjusted hours per resident day): greater than or equal to
0.402 - less than 0.550;
Registered nurses Total nursing[B]: greater than or equal to 3.842 -
less than 4.080.
Star rating[A]: 5;
Definition: At or exceeding the thresholds based on a 2001 CMS
staffing study[D];
Range (adjusted hours per resident day): greater than or equal to
0.550;
Registered nurses Total nursing[B]: greater than or equal to 4.080.
Source: CMS.
[A] CMS has developed an approach for assigning staffing ratings when
ratings for registered nurse and total nursing staffing differ. See
Centers for Medicare & Medicaid Services, Design for Nursing Home
Compare Five-Star Quality Rating System: Technical Users' Guide
(Baltimore, Md.: July 2010).
[B] Total nursing refers to the sum of registered nurses, licensed
practical nurses, and certified nursing assistants.
[C] Each nursing home's staffing rating is assigned based on how its
total nursing and registered nurse staffing levels compared to the
distribution of staffing levels for freestanding facilities in the
nation. The thresholds are based on the distribution of staffing data
for freestanding facilities reported to CMS as of November 4, 2008.
[D] These thresholds are based on a 2001 CMS staffing study conducted
to examine the levels at which nursing home staffing levels relate to
improved quality of care. See AM Kramer and R. Fish, Abt Associates,
"The Relationship Between Nurse Staffing Levels and the Quality of
Nursing Home Care," chapter 2 in Appropriateness of Minimum Nurse
Staffing Ratios in Nursing Homes: Phase II Final Report, a report
prepared at the request of CMS (2001).
[End of table]
Quality Measure Rating:
Each nursing home's quality measure rating is calculated based on the
nursing home's performance over the three most recent
quarters[Footnote 47] on 10 of 19 quality measures,[Footnote 48]
including 7 long-stay and 3 short-stay measures.[Footnote 49] Two of
the long-stay measures capture aspects of activities of daily living,
which reflect nursing home residents' ability to provide self-care.
Performance on the two activities of daily living-related measures is
weighted 1.6667 times as high as the other measures. This, according
to CMS, reflects the greater importance of these measures to many
nursing home residents and ensures that the two activities of daily
living measures count for 40 percent of the overall weight of the long-
stay measures. For the individual quality measures used to calculate
this rating, nursing homes that have lower percentages are considered
to have higher quality of care and, thus, receive more points. For
example, for one of the quality measures used in the Five-Star System--
the percentage of patients who were physically restrained--nursing
homes with lower percentages of patients who were physically
restrained are considered to have higher quality of care. As a result,
those nursing homes receive more points towards their quality measure
rating than facilities in which a higher percentage of residents are
physically restrained. The points received for all quality measures
are summed to create a total score for each facility with a higher
point total equating to a better quality measure star rating.[Footnote
50] Quality measure ratings are then assigned to generally achieve the
following distribution: the top 10 percent of nursing homes receive
five stars, the bottom 20 percent receive one star, and the middle 70
percent of nursing homes receive two, three, or four stars, with equal
proportions (23.33 percent) in each category.[Footnote 51]
Overall Rating:
Each nursing home's overall rating is based on its ratings for the
three components--health inspections, staffing, and quality measures.
From these three ratings, the overall rating is assigned based on the
following steps:
1. Start with the number of stars for the health inspection rating.
2. Add one star if the staffing rating is four or five stars and also
greater than the health inspection rating. Subtract one star if the
staffing rating is one star. The rating cannot go above five stars or
lower than one star.
3. Add one star if the quality measure rating is five stars. Subtract
one star if the quality measure rating is one star. The rating cannot
go above five stars or lower than one star.
If the health inspection rating is 1 star, then the overall rating
cannot be upgraded by more than one star based on the staffing and
quality measure ratings. In addition, if a nursing home is a Special
Focus Facility[Footnote 52] that has not graduated, the maximum
overall rating allowable is 3 stars.
[End of section]
Appendix III: Comments from the Department of Health and Human
Services:
Department Of Health & Human Services:
Office of The Secretary:
Assistant Secretary for Legislation:
Washington, DC 20201:
March 5, 2012:
Linda T. Kohn:
Director, Health Care:
U.S. Government Accountability Office:
441 G Street NW:
Washington, DC 20548:
Dear Ms. Kohn:
Attached are comments on the U.S. Government Accountability Office's
(GAO) report entitled, "Nursing Homes: CMS Needs Milestones and
Timelines to Ensure Goals for the Five-Star Quality Rating System Arc
Met" (GAO-12-390).
The Department appreciates the opportunity to review this draft
section of the report prior to publication.
Sincerely,
Signed by:
Jim R. Esquea:
Assistant Secretary for Legislation:
Attachment:
[End of letter]
General Comments Of The Department Of Health And Human Services (HHS)
On The Government Accountability Office's (GAO) Draft Report Entitled,
"Nursing Homes: CMS Needs Milestones And Timelines To Ensure Goals For
The Five-Star Quality Rating System Are Met" (GAO-12-390):
In 2008 the Centers for Medicare & Medicaid Services (CMS) created the
Five Star Nursing Home Quality Rating System with broad input from
stakeholders, researchers and contract research firms. The GAO report
notes that CMS has modified the Five Star Nursing Home Quality Rating
System, "in response to (1) methodological issues raised by
stakeholders, (2) its routine monitoring of the system, and (3) the
availability of new data sources."
The CMS is implementing additional improvements to the Nursing Home
Compare website. This includes new information about the number of
substantiated complaints, the result of CMS complaint investigations,
monetary fines levied against nursing homes, and new quality measures
that will be possible as we complete the transition to reporting on
the new Minimum Data Set (MDS) 3.0. As noted in the report, in the
future we intend to add information about nursing home ownership and
nursing homes' special capabilities. These additions (and others are
likely to emerge) suggest the need for a more formal strategic plan
for modifying the site and ensuring that the site meets CMS' goal of
informing consumers and improving provider quality.
The CMS developed Nursing Home Compare in 1998. The goal of Nursing
Home Compare was and remains to provide consumers with easily
accessible and understandable information that will allow consumers to
make informed choices about nursing homes. Since 1998, CMS has
steadily expanded the site in response to stakeholder input and its
own analyses. In 1999, for example, CMS added information about
nursing home staffing. In 2001, CMS added the results of complaint
surveys. In 2003, CMS began reporting quality measures for nursing
homes. In 2007, CMS added information about fire safety inspections
and began identifying Special Focus Facilities. And in 2008 CMS began
publishing the Five Star Nursing Home Quality Rating System.
The significant expansion of information on Nursing Home Compare
resulted in a very complex website, a fact that a number of
stakeholders, including members of Congress, noted. For example,
Nursing Home Compare reports the results of nearly 200,000 nursing
home inspections and about 300,000 quality measure values. The Five
Star Nursing Home Quality Rating System therefore offers consumers a
convenient way to summarize the vast amount of information available
on the website.
The report also notes that CMS has "several planned efforts intended
to improve the system the Five Star System" and recommends that CMS
adopt "milestones and timelines to guide and gauge progress toward
achieving desired results and the alignment of activities, resources,
and goals."
The GAO also recommends that CMS more rigorously tie its "planned
efforts to improve the Five-Star system" to CMS' stated goals of
informing consumers and improving provider quality. CMS concurs fully
with the GAO's findings and recommendation. The GAO recommendations
and the CMS response to those recommendations are discussed below.
GAO Recommendation 1:
In order to strengthen CMS's efforts to improve the Five-Star System,
the GAO recommends that the Administrator of CMS use strategic
planning practices to establish—through planning documents—how its
planned efforts will help CMS achieve the goals of the Five Star
System.
CMS Response:
The CMS concurs with this recommendation. CMS will work to develop a
strategic plan for Nursing Home Compare and the Five Star System that
addresses CMS' short- and long-term goals for the site and the ways in
which CMS may best achieve those goals. As part of this strategic
plan, CMS will develop a mechanism for receiving regular and
systematic input from consumers, as well as from stakeholders.
GAO Recommendation 2:
In order to strengthen CMS's efforts to improve the Five-Star System,
the GAO recommends that the Administrator of CMS use strategic
planning practices to develop milestones and timelines for each of its
planned efforts.
CMS Response:
The CMS concurs with this recommendation. Along with a strategic plan,
we will develop a timeline and milestones for meeting the CMS' goals.
CMS acknowledges that both the strategic plan and specific timelines
and milestones are critical for-—(1) Measuring CMS' progress towards
meeting its goals; and (2) Budgeting for the resources needed to meet
those goals.
The CMS appreciates the opportunity to comment on this draft report
and we look forward to working with GAO on this and other issues.
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Linda Kohn, (202) 512-7114 or kohnl@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Karen Doran, Assistant
Director; Danielle Bernstein; Deirdre Brown; Krister Friday; Giselle
Hicks; Melanie Krause; Lisa Motley; and Jessica Smith made key
contributions to this report.
[End of section]
Footnotes:
[1] Medicare is the federal health insurance program for persons aged
65 or over, certain disabled individuals, and individuals with end-
stage renal disease. Medicaid is the joint federal-state health care
financing program for certain categories of low-income individuals.
[2] See GAO, Nursing Homes: Addressing the Factors Underlying
Understatement of Serious Care Problems Requires Sustained CMS and
State Commitment, [hyperlink, http://www.gao.gov/products/10-70]
(Washington, D.C.: Nov. 24, 2009), and Poorly Performing Nursing
Homes: Special Focus Facilities Are Often Improving, but CMS's Program
Could Be Strengthened, [hyperlink,
http://www.gao.gov/products/GAO-10-197] (Washington, D.C.: Mar. 19,
2010).
[3] [hyperlink, http://www.Medicare.gov/NHCompare/home.asp].
[4] Long-term care stakeholders include nursing home providers,
consumers, and advocacy groups that represent consumers or providers.
[5] Pub. L. No. 111-148, § 6107, 124 Stat. 119, 713 (2010).
[6] The CMS Five-Star System contractor is a consulting firm that
employs health services researchers and other support staff and
conducts research in a range of fields, including health care policy.
[7] GAO, Managing for Results: Enhancing Agency Use of Performance
Information for Management Decision Making, [hyperlink,
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: Sept. 9,
2005); Agency Performance Plans: Examples of Practices That Can
Improve Usefulness to Decisionmakers, [hyperlink,
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, D.C.:
Feb. 26, 1999); Agencies' Strategic Plans Under GPRA: Key Questions to
Facilitate Congressional Review, [hyperlink,
http://www.gao.gov/products/GAO/GGD-10.1.16] (Washington, D.C.: May
1997); Managing for Results: Critical Issues for Improving Federal
Agencies' Strategic Plans, [hyperlink,
http://www.gao.gov/products/GAO/GGD-97-180] (Washington, D.C.: Sept.
16, 1997); and Executive Guide: Effectively Implementing the
Government Performance and Results Act, [hyperlink,
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June
1996).
[8] Government Performance and Results Act of 1993, Pub. L. No. 103-
62, 107 Stat. 285 (1993) and the GPRA Modernization Act of 2010, Pub.
L. No. 111-352, 124 Stat. 3866 (2011).
[9] CMS initially reported information about nursing home
characteristics and survey results on its Nursing Home Compare
website. Later, CMS began reporting additional information, such as
the ratio of nursing staff to residents.
[10] Some nursing homes may have fewer than four ratings because CMS
does not assign a rating if certain criteria established by CMS are
not met, such as reporting reliable data.
[11] See 42 U.S.C. §§ 1395i-3(g)(2)(A)(iii), 1396r(g)(2)(A)(iii).
[12] CMS started posting the results of surveys on Nursing Home
Compare in 1998. According to CMS, the strengths of the surveys are
that they are conducted by trained individuals and follow national
standards. Also, according to CMS, limitations of these surveys are
that the data are only collected about one time a year and deficiency
citations are subject to the interpretation of the trained state
surveyor.
[13] Total nursing hours are the sum of registered and licensed
practical nurse and certified nursing assistant hours. In 2000, CMS
began publicly reporting information on nursing home staffing levels
on Nursing Home Compare. According to CMS, the strength of staffing
data is that there is a relationship between staffing and quality of
care and that staffing data collected by CMS are understandable for
the consumer. In addition, according to CMS, a limitation of these
data is that they are self-reported by nursing home staff about one
time per year.
[14] CMS measures resident acuity using the Resource Utilization Group
(RUG)-III case mix system that uses resident assessment data routinely
collected in MDS. This system classifies residents into 1 of 53
categories according to predicted resource needs, particularly the
expected amount of staff time required to care for residents. In
October 2010, CMS implemented a new version of MDS--MDS 3.0--and this
will change the data used for the case mix system.
[15] Freestanding nursing homes are those that are not under
administrative control of a hospital.
[16] See AM Kramer and R. Fish, Abt Associates, "The Relationship
Between Nurse Staffing Levels and the Quality of Nursing Home Care,"
chapter 2 in Appropriateness of Minimum Nurse Staffing Ratios in
Nursing Homes: Phase II Final Report, a report prepared at the request
of CMS (2001).
[17] In 2002, CMS began posting nursing homes' quality measures on
Nursing Home Compare. According to CMS, the strengths of the quality
measures are that they are an in-depth look at key aspects of care and
are validated through a formal process. In addition, CMS notes that
limitations of the quality measures are that the data for these
measures are self-reported by nursing home staff and that quality
measures are narrowly focused on specific aspects of quality of care.
[18] Performance on the two activities of daily living-related
measures is weighted 1.6667 times as high as the other measures. In
addition, thresholds for the two activities of daily living quality
measures are reset with each quarterly update of the quality measures
data based on the state-specific distribution of these measures.
Thresholds for the other quality measure ratings are fixed based on
the national distribution of these measures on January 5, 2009.
[19] The overall rating is capped in two circumstances. First, if a
nursing home's health inspection rating is one star, then the overall
rating cannot exceed two stars. Second, nursing homes currently in the
Special Focus Facility Program--a program that aims to remedy
noncompliance with federal quality standards in nursing homes with
repeated cycles of noncompliance with these standards--have their
overall rating capped at three stars even if they have high ratings in
individual components.
[20] CMS convenes Open Door Forums to provide an opportunity for
dialogue between CMS and the provider community and others to help
them to understand contemporary program issues, such as the
development of new rating systems.
[21] CMS summarized comments it received on the Five-Star System
through July 23, 2008. CMS continued to receive comments on the Five-
Star System via email (BetterCare@cms.hhs.gov) after July 23, 2008,
though those comments were not included in CMS's summary of comments
on the system.
[22] For a list of the current technical expert panel members, see
https://www.cms.gov/CertificationandComplianc/13_FSQRS.asp].
[23] For an overview of our approach to identify the key
methodological decisions CMS made during the development of the Five-
Star System, which includes a list of other methodological decisions
that technical expert panel members identified as eliciting intense
review and discussion, see appendix I.
[24] Hospital-based nursing homes are under administrative control of
a hospital. In contrast, freestanding nursing homes are those that are
not under administrative control of a hospital.
[25] Nursing homes with a one star health inspection rating cannot be
upgraded by more than one star based on the staffing and quality
measure ratings. In addition, nursing homes that are enrolled in CMS's
Special Focus Facility Program are identified as such on the website
and have a maximum overall rating of three stars. For additional
information about the methodology to calculate the overall rating, see
appendix II.
[26] See C. Harrington, C. Kovner, M. Mezey, J. Kayser-Jones, S.
Burger, M. Mohler, R. Burke, and D. Zimmerman, "Experts Recommend
Minimum Nurse Staffing Standards for Nursing Facilities in the United
States," The Gerontologist, vol. 40, no. 1 (2000), 5-16.
[27] CMS measures resident acuity using the Resource Utilization Group
(RUG)-III case mix system. This system classifies residents into 1 of
53 categories according to predicted resource needs, particularly the
expected amount of staff time required to care for residents, using
resident assessment data that are routinely collected by CMS from
nursing homes.
[28] A senior CMS official told us that while they do not track each
issue that has been raised, they write internal memorandums for issues
that were raised that outline the reasoning behind whether
modifications were or were not made to the Five-Star System.
[29] CMS conducted a retrospective analysis of health inspection
ratings from 2003 through 2008 and found that the scores of nursing
homes would have declined during this period if a Five-Star System
with fixed thresholds had been in place.
[30] Through this analysis, CMS has found that nursing homes' star
ratings have improved in the first 2 years since the Five-Star System
has been implemented, but it is unclear if the results are due to more
accurate reporting of the data or an actual improvement in quality.
[31] The Quality Indicator Survey is an electronic process to conduct
surveys that began in 2005. As of November 2011, the implementation of
the Quality Indicator Survey had been postponed in an effort to
address concerns that have been raised about this new process. For
more information about GAO's work on the Quality Indicator Survey, see
Nursing Home Quality: CMS Should Improve Efforts to Monitor
Implementation of the Quality Indicator Survey, [hyperlink,
http://www.gao.gov/products/GAO-12-214] (Washington, D.C.: Feb. 1,
2012).
[32] CMS anticipates launching the revised Nursing Home Compare
website in July 2012.
[33] Five of the participants were currently researching or had
recently researched nursing homes for a family member and four
participants were professionals who assist clients in finding nursing
homes.
[34] CMS had September 2011 through early January 2012 to conduct
evaluations and develop a proposal for the revised website so that the
revisions could be incorporated and the revised website launched in
July 2012. To prepare for the redesign, in October and November 2011,
CMS also had contractors conduct an evaluation of the current website
based on industry website design standards.
[35] Short-stay residents are those who typically enter a nursing home
for a short period of time, such as after a hospitalization. In
contrast, long-stay residents are those with chronic conditions who
are typically long-term residents of a facility.
[36] The staffing component rating is based on the nursing staff
levels (registered nurse, certified nursing assistant, and licensed
practical nurse) at a nursing home. Therapy staff provide nursing home
residents with rehabilitative services and may include occupational
therapists, physical therapists, and speech/language pathologists.
[37] CMS also has a contract with another contractor to develop new
nursing home quality measures, with a particular emphasis on measures
for short-stay nursing home care. However, this contract is for the
development of nursing home quality measures more broadly and is not
specific to quality measures for use in the quality measure component
of the Five-Star System. This contractor is also currently developing
a new quality measure related to rehospitalizations of short-stay
nursing home residents. It would measure the percentage of Medicare
short-stay nursing home residents who, after being discharged from an
acute care hospital, return to the hospital for any reason during
their stay in the nursing home or within 30 days after discharge from
the nursing home. CMS estimates that this quality measure will be
finalized in the fall of 2012. Subsequently, CMS will consider this
measure for use in the quality measure component of the Five-Star
System.
[38] [hyperlink, http://www.gao.gov/products/GAO/GGD/AIMD-99-69] and
[hyperlink, http://www.gao.gov/products/GAO/GGD-96-118].
[39] [hyperlink, http://www.gao.gov/products/GAO/GGD-96-118] and
[hyperlink, http://www.gao.gov/products/GAO/GGD-97-180].
[40] AHRQ has developed and disseminated best practices for the public
reporting of health care quality information to consumers. AHRQ has
reported that good consumer testing will not ask respondents if they
understand the information presented, but rather, will ask them a
knowledge question to determine if they are interpreting the
information presented correctly. See S. Sofaer and J. Hibbard, Best
Practices in Public Reporting No. 2: Maximizing Consumer Understanding
of Public Comparative Quality Reports: Effective Use of Explanatory
Information, AHRQ Publication No. 10-0082-1-EF (Rockville, Md.: Agency
for Healthcare Research and Quality, June 2010) and S. Sofaer and J.
Hibbard, Best Practices in Public Reporting No.1: How to Effectively
Present Health Care Performance Data to Consumers, AHRQ Publication
No.10-0082-2-EF (Rockville, Md.: Agency for Healthcare Research and
Quality, June 2010).
[41] In the summer of 2009, CMS used a pop-up survey on its Nursing
Home Compare website that included some questions related to the Five-
Star System to gather very general reactions to the website. In
addition, in November 2010, CMS asked participants in its Medicare
Users Group--a focus group used by CMS to get early, high-level
feedback on potential modifications to Medicare.gov--five questions
regarding Nursing Home Compare, two of which focused on the Five-Star
System. To date, CMS has not made any changes to the Five-Star System
based on the information gathered.
[42] CMS convened a technical expert panel to provide recommendations
on the development of the Five-Star System. This panel is composed of
nine members that CMS and its contractor identified as experts in long-
term care research and included researchers and an industry
representative. For a list of the current technical expert panel, see
[hyperlink,
https://www.cms.gov/CertificationandComplianc/13_FSQRS.asp].
[43] Points from more recent surveys are weighted more heavily. The
most recent year's survey is assigned a weighing factor of 1/2, the
previous survey has a weighing factor of 1/3, and the second prior
survey has a weighing factor of 1/6.
[44] Resident acuity refers to the complexity of nursing services
required to care for residents, as measured using the Resource
Utilization Group (RUG)-III case mix system. This system classifies
residents into 1 of 53 categories according to predicted resource
needs, particularly the expected amount of staff time required to care
for residents, using resident assessment data that are routinely
collected and reported to CMS by nursing homes using a resident
assessment tool called the Minimum Data Set (MDS). Currently, resident
acuity is measured using data from an older version of MDS that was
collected through September 30, 2010. One CMS official told us that
the agency anticipates beginning to use data from a new version of MDS
to measure resident acuity beginning around April 2012.
[45] Freestanding nursing homes are those that are not under
administrative control of a hospital. In contrast, hospital-based
nursing homes are under administrative control of a hospital.
[46] See AM Kramer and R. Fish, Abt Associates, "The Relationship
Between Nurse Staffing Levels and the Quality of Nursing Home Care,"
chapter 2 in Appropriateness of Minimum Nurse Staffing Ratios in
Nursing Homes: Phase II Final Report, a report prepared at the request
of CMS (2001).
[47] CMS has not updated the quality measure ratings in the Five-Star
System since January 2011, while CMS collects resident information
from nursing homes using the new version of MDS--MDS 3.0--which was
implemented in October 2010 and refines and tests quality measures
using this new assessment tool. CMS is currently considering options
for how to refine the quality measure rating based on these new data.
[48] CMS selected these quality measures, with input from its Five-
Star System contractor and members of a Five-Star System technical
expert panel--a panel composed of nine individuals that CMS identified
as experts in long-term care research--based on their validity and
reliability, the extent to which the measure is under the facility's
control, statistical performance, and importance.
[49] Short-stay measures are those that are intended to assess quality
of care for residents who typically enter a nursing home for a short
period, such as after a hospitalization. In contrast, long-stay
measures are those that are intended to assess quality of care for
residents with chronic conditions who are typically long-term
residents of a facility.
[50] CMS has developed an approach for accounting for missing data for
individual quality measures when calculating quality measure ratings.
See Centers for Medicare & Medicaid Services, Design for Nursing Home
Compare Five-Star Quality Rating System: Technical Users' Guide
(Baltimore, Md.: 2010).
[51] Thresholds for the two activities of daily living quality
measures are reset with each quarterly update of the quality measure
data based on the state-specific distribution of these measures.
Thresholds for the other quality measure ratings are fixed based on
the national distribution of these measures on January 5, 2009.
[52] The Special Focus Facility Program is a program that aims to
remedy noncompliance with federal quality standards in nursing homes
with repeated cycles of noncompliance with these standards. For
additional information about this program, see GAO, Nursing Homes:
CMS's Special Focus Facility Methodology Should Better Target the Most
Poorly Performing Homes, Which Tended to Be Chain Affiliated and For-
Profit, [hyperlink, http://www.gao.gov/products/GAO-09-689]
(Washington, D.C.: Aug. 28, 2009) and Poorly Performing Nursing Homes:
Special Focus Facilities Are Often Improving, but CMS's Program Could
Be Strengthened, [hyperlink, http://www.gao.gov/products/GAO-10-197]
(Washington, D.C.: Mar. 19, 2010).
[End of section]
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